Every year, we see the same pattern at our firm: a company that hasn’t touched its overseas investment in years suddenly realises, sometime in June, that it still owes the RBI a return. The Foreign Liabilities and Assets (FLA) Return catches people off guard precisely because it doesn’t ask “did anything happen this year?” It asks “what’s still sitting on your books on 31 March?” That one distinction trips up more businesses than almost any other FEMA filing we handle.
FLA Return Filing 2026
Every Indian company, LLP, partnership firm, or SEBI-registered AIF holding outstanding Foreign Direct Investment (FDI) or Overseas Direct Investment (ODI) as of 31 March must file the Foreign Liabilities and Assets (FLA) Return with the RBI under FEMA, 1999. The return is filed online via the FLAIR portal and is due every year by 15 July, irrespective of whether financial statements have been audited by that date.
What is the FLA Return?
The FLA Return is an annual filing under the Foreign Exchange Management Act (FEMA), 1999, through which Indian resident entities report their outstanding foreign assets and liabilities as on 31 March of the relevant financial year. The Reserve Bank of India (RBI) uses this data to compile the country’s Balance of Payments (Bop) and International Investment Position (IIP).
This is worth distinguishing from event-based FEMA filings such as Form FC-GPR (share allotment) or Form FC-TRS (transfer of shares), which are triggered by a specific transaction during the year. The FLA Return works differently: it is not concerned with whether a transaction occurred, it is only concerned with whether foreign assets or liabilities remain outstanding on the balance sheet as on 31 March. This is the most common point of confusion we encounter – entities often assume that no activity during the year means no filing obligation, when in fact the obligation is determined solely by the year-end position.
Who Must File the FLA Return?
Any Indian resident entity with outstanding foreign investment must file, including:
- Companies (private, public, and Section 8)
- Limited Liability Partnerships (LLPs)
- Partnership firms
- Public-Private Partnerships (PPPs)
- SEBI-registered Alternative Investment Funds (AIFs)
- Other resident entities holding foreign investments or obligations
Quick Decision Check
Here’s a quick way to check:
| Situation |
FLA Filing Required? |
| Indian company received FDI, still holds the investment on 31 March |
Yes |
| Indian company made ODI in a foreign JV/WOS, still outstanding |
Yes |
| FDI/ODI fully exited or written off before 31 March, nothing outstanding |
No |
| Company received share application money only, shares not yet allotted |
No (report under late submission once allotted, but not as FLA) |
| LLP or AIF made overseas investment (ODI) abroad, still outstanding |
Yes |
| LLP or AIF received foreign investment (FDI) into the entity, still outstanding |
Yes |
Who is Exempt?
An entity with no outstanding foreign assets or liabilities as on 31 March is not required to file. This commonly applies where foreign investment has been fully exited, repatriated, or written off before the financial year-end. The catch is that this needs to be checked every single year. We’ve seen entities assume a past exemption carries forward; it doesn’t.
FLA Return Due Date for FY 2025-26
The FLA Return must be filed by 15 July 2026 for the financial year ending 31 March 2026. If audited financial statements are not ready by the due date, the entity should still file using provisional or unaudited figures, and revise the return once the audit is complete. Filing late, or not revising provisional figures after audit, can attract penalties under FEMA.
The 31 March cut-off applies irrespective of the foreign investor’s own accounting year. Many overseas parent companies and investors follow a calendar year (January–December) for their own books, but the FLA Return always follows the Indian entity’s financial year. There is no provision to align the return with the investor’s reporting calendar.
Unsure whether your entity is even covered this year? Our FEMA team can confirm applicability and handle the FLAIR filing end to end.
Information Required in the FLA Return
The FLAIR portal expects fairly detailed financial inputs, not just a yes/no declaration. The portal collects details such as:
- Foreign equity participation (inbound and outbound)
- Foreign liabilities and assets outstanding at year-end
- Overseas investments (ODI) including JV/WOS details
- External Commercial Borrowings (ECBs)
- Reserves and surplus, and other balance sheet items
- Financial performance indicators (sales, profit, etc.)
- Ownership structure of foreign investment (% holding, country of investor)
Most of the back-and-forth we see during filing season comes down to one or two of these line items not tying back cleanly to the audited balance sheet — worth checking early rather than at the deadline.
How to File: The FLAIR Portal Process
The FLA Return is filed electronically through the RBI’s Foreign Liabilities and Assets Information Reporting (FLAIR) portal. The broad steps are:
- Register the entity on the FLAIR portal (one-time registration, then renew login annually)
- Select the applicable return type and financial year
- Fill in balance sheet, equity, and investment details
- Validate the data using the portal’s built-in checks
- Submit and retain the system-generated acknowledgment
Consequences of Non-Compliance
Missing the FLA deadline, or failing to revise a provisional filing after the audit is completed, is treated as a contravention under FEMA. Depending on the nature and duration of the default, this can lead to monetary penalties, and continuing defaults can attract an additional daily penalty until the return is filed.
If a past year’s FLA filing may have been missed or filed incorrectly, it’s worth getting it reviewed before it surfaces during a deal or audit.
Why FLA Compliance Matters
Beyond avoiding penalties, staying current on FLA filings has practical benefits for how your entity is viewed by regulators, auditors, and investors:
- Avoids monetary penalties and regulatory scrutiny under FEMA
- Keeps the entity’s foreign investment record clean for future fundraising or ODI
- Supports smoother FEMA compliance during due diligence, M&A, or RBI queries
- Contributes accurate data to India’s external sector statistics
We’ve seen FLA gaps surface during due diligence on unrelated deals — a buyer’s counsel runs a FEMA compliance check, finds a missed year, and suddenly a clean transaction has an unplanned remediation step attached to it.
Frequently Asked Questions on FLA Return
Q1: What is the due date for filing the FLA Return?
The FLA Return must be filed by 15 July 2026 for the financial year ending 31 March 2026, through the RBI’s FLAIR portal. If audited accounts aren’t ready, file with provisional figures and submit a revised return once the audit is finalised.
Q2: Where is the FLA Return filed?
The FLA Return is filed online through the RBI’s Foreign Liabilities and Assets Information Reporting (FLAIR) portal. There is no physical or email submission – the entity registers on the portal, enters the required financial details, validates them, and submits electronically to receive an acknowledgment.
Q3: Does a company have to file FLA if it received FDI but made no foreign transaction this year?
Yes. The FLA Return is based on the year-end balance sheet position, not on whether a transaction took place during the year. As long as foreign investment remains outstanding on 31 March, filing is mandatory.
Q4: Is FLA filing required if the foreign investment was fully exited before 31 March?
No. If an entity has no outstanding foreign assets or liabilities as on 31 March, it is exempt from filing for that year.
Q5: Can the FLA Return be filed using provisional financial figures?
Yes. Where audited financial statements are not available by 15 July, the entity can file using provisional or unaudited figures and must submit a revised return after the audit is completed.
Q6: Does this apply only to companies, or also to LLPs and funds?
LLPs, partnership firms, and SEBI-registered AIFs are all covered, alongside companies and PPPs. The entity type doesn’t matter — what matters is whether foreign assets or liabilities are outstanding on 31 March.
Q7: What happens if FLA return is not filled?
A missed deadline is treated as a contravention under FEMA and can attract monetary penalties, with continuing defaults potentially leading to additional daily penalties until the return is filed.
Q8: Do LLPs and AIFs also need to file the FLA Return, or is it only for companies?
LLPs, partnership firms, and SEBI-registered AIFs are also covered, along with companies and PPPs, as long as they hold outstanding foreign assets or liabilities as on 31 March.
How we Can Help
S K Patodia & Associates LLP advises Indian companies, LLPs, and funds on end-to-end FLA Return compliance under FEMA. Our support includes:
- Assessing FLA applicability based on outstanding FDI, ODI, or other foreign liabilities/assets as on 31 March.
- Compiling and reconciling FDI and ODI data accurately from your balance sheet and investment records.
- Registering and filing the return on the RBI’s FLAIR portal within the 15 July deadline.
- Advising on FLA exemption analysis where foreign investment has been fully exited or written off.
- Coordinating with auditors and the finance team to avoid last-minute discrepancies.
- Ongoing FEMA advisory to prevent future RBI scrutiny, penalties, or compounding proceedings.
If your Company, LLP, or fund has any outstanding FDI, ODI, or foreign liability as on 31 March 2026, reach out to us before the 15 July deadline to get your FLA Return filed accurately and on time.
We hope that the Article has given you the clarity needed on FLA Return compliance under FEMA. If you have any queries or wish to review your specific situation, feel free to get in touch with our team.
